How often must hazardous chemical agent monitoring be done?

Short answer: at least every 24 months. Under the Regulations for Hazardous Chemical Agents, 2021, air monitoring by an approved inspection authority must be repeated at least every 24 months for each agent with an occupational exposure limit in Table 2 or 3 of Annexure 2 to which employees may be exposed. The exposure assessment that decides whether monitoring is needed must be redone at intervals not exceeding two years, and reviewed immediately when something changes.

The regulations were published as Government Notice R. 280 in Government Gazette 44348 on 29 March 2021 and repealed the Regulations for Hazardous Chemical Substances, 1995. They apply where work may expose people to a hazardous chemical agent (HCA), except where the Lead Regulations or Asbestos Abatement Regulations apply. Air monitoring and medical surveillance (regulations 6 and 7) do not apply to self-employed persons or to people visiting the workplace (regulation 2(2)). What the regulations require gives the full overview; this article covers the intervals.

The intervals at a glance

• Exposure assessment (regulation 5(1)): immediately, then at intervals not exceeding two years, after consulting the health and safety representative or committee.

• Air monitoring (regulation 6): representative measurements at least every 24 months for each HCA with an OEL-ML or OEL-RL in Table 2 or 3 of Annexure 2, carried out by an approved inspection authority (AIA). The health and safety representative or committee must be informed beforehand and given a reasonable opportunity to comment.

• Medical surveillance (regulation 7(2)): for employees under surveillance, such as those exposed to agents in Table 4 of Annexure 2, an initial health evaluation by an occupational health practitioner immediately before or within 14 days after starting, then examinations at intervals not exceeding two years or at intervals an occupational medicine practitioner specifies.

• Engineering controls (regulation 12(b)): thorough examinations and tests by an AIA at intervals not exceeding 24 months. LEV testing explains what this involves for extraction systems.

• Training (regulation 3(1)): before exposure, then at intervals recommended by the health and safety committee.

• Records (regulation 9): assessment and air monitoring records for at least 30 years, and records of the engineering control tests and resulting repairs for at least three years.

Do the results change the interval?

No. Regulation 6 sets one maximum interval and does not tie it to the results. There is no shorter legal interval when results are close to the OEL, and no longer one when they are low: 24 months is the maximum for every agent in Tables 2 and 3. Monitoring is required while the assessment shows that employees may be exposed (regulation 5(4)), so it falls away only when that is no longer the case, for example because the agent has been eliminated.

Twenty-four months is a maximum, not a target. Where results are close to a limit, where controls have just been installed or changed, or where the agent has a maximum limit, measuring more often shows whether the controls work before the next compulsory round. Occupational exposure limits explained covers how results are judged against maximum and restricted limits.

When you can't wait 24 months

Regulation 5(5) requires an immediate review of the assessment if:

• there is reason to suspect that the previous assessment is no longer valid; or

• there has been a change in a process involving an HCA, or in the methods, equipment or procedures for its use, handling, control or processing.

Typical triggers are a new product or a reformulated one, a switch from mild steel to stainless steel welding, new or failed extraction, and complaints of symptoms. If the reviewed assessment shows that employees may be exposed, regulation 5(4) requires monitoring under regulations 6 and 7. In practice, measure the changed process rather than waiting for the next scheduled round.

A quick self-check

• Find the date of your last HCA survey by an approved inspection authority. If it is approaching 24 months, book the next one now.

• Check the date of your exposure assessment, and whether it was reviewed after the last change in products, processes or equipment.

• Confirm that the health and safety representative or committee was told about the last survey before it took place, and has seen the assessment results.

• Check that extraction systems and other engineering controls had a thorough examination and test within the last 24 months.

• Check medical surveillance dates, and that new starters had their initial evaluation within 14 days of starting.

• Confirm that assessment and monitoring reports are kept for at least 30 years.

How Qualitas can help

Qualitas Occupational Consulting is a Department of Employment and Labour Approved Inspection Authority and a SANAS-accredited (ISO/IEC 17020) inspection body for asbestos, lead, noise and hazardous chemical agents. Our hazardous chemical agents surveys provide the regulation 6 monitoring: we plan representative sampling with you, measure exposure during normal work, and compare the results with the Annexure 2 limits, in a report written for management, SHEQ teams and auditors.

Not sure which parts of your programme need an AIA? See approved inspection authority or competent person: who may do what?

Not sure what your site needs? Start with our free Compliance Gap Analysis, request a quote, or call or WhatsApp 082 649 6599.

This article summarises the Regulations for Hazardous Chemical Agents, 2021 (Government Notice R. 280, Government Gazette 44348, 29 March 2021) for general guidance. It is not legal advice; refer to the regulations for the full requirements.

Christo de Wet is a SAIOH-registered occupational hygienist with 15 years' experience and the founder of Qualitas Occupational Consulting.